College Summit Inc.

“The federal form 990 is reviewed by the chief executive officer and the director of finance. The draft federal form 990 is then presented to the finance committee and finally to the board of directors before submission to the internal revenue service.”

“Currently there are two conflict of interest policies in place. One is for employees and one for board members. The following process is for employees: - all new hires receive a copy of the conflict of interest policy and sign receipt of reading and understanding the policy. - employees are notified of the whistle blowing policy that ensures protection from retaliation of employee's reporting conflict of interest violations or other infractions. - all employees are provided with copies of all policies in the employee handbook as well. The following process is for board members: - board members are given the conflict of interest policy when they join the board of directors. The secretary (and/or vp, human resources) to the board of directors provides an overview of the policy. - annually board members sign a certificate of acknowledgment of having received a copy, and read the policy. The certificate of acknowledgement is then reviewed by the general counsel. If the board has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose. If, after hearing the member's response and after making further investigation as warranted by the circumstances, the board of directors determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate corrective or disciplinary action.”

“The executive committee of the board of directors is authorized to make recommendations to the board of directors regarding executive compensation. The executive committee's process in setting compensation shall include all of these elements: (1) review and approval by the board of directors as provided for in the bylaws; (2) use of comparable compensation data; and (3) contemporaneous documentation and recordkeeping. Review and approval - the compensation of the ceo is reviewed and approved by the board of directors, provided that persons with conflicts of interest with respect to the compensation arrangement at issue are not involved in this review and approval. Use of comparable compensation data - the compensation of the person is reviewed and approved using comparable compensation data for similarly qualified persons in functionally comparable positions at similarly situated organizations. Contemporaneous documentation and recordkeeping - there is contemporaneous documentation and recordkeeping with respect to the deliberations and decisions regarding the compensation arrangement. The executive committee shall make this determination at least once annually. Final board action - only those directors who are free of conflicts of interest may vote on executive compensation. The board of directors review and approve ceo compensation, after a review of comparability data or other evidence that compensation is reasonable, and contemporaneously substantiate its deliberation and decision in the minutes. In regards to the non-ceo salary, each year the board of directors reviews and approves a fiscal year budget, one element of which includes any proposed salary adjustments and the bases therefore. A full compensation analysis/study for the entire organization (including the ceo) was last performed in january 2023.”

“Peerforward makes its governing documents and conflict of interest policy available to the public upon request. Peerforward's federal form 990 and financial statements are available to the public on peerforward's website.”